DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTRUCTURE LTD., MUMBAI

In the result, both the appeals of the revenue are allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

section 801A(4)(i) of the IT Act, 1961. 2. Assessee paid contract price as per contractual obligations on completion of work and TDS

DCIT-1(2)1, MUMBAI, MUMBAI vs. PATIL CONSTRUCTION AND INFRASTUCTURE LIMITED., MUMBAI

In the result, both the appeals of the revenue are allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

section 801A(4)(i) of the IT Act, 1961. 2. Assessee paid contract price as per contractual obligations on completion of work and TDS

DCIT CC- 3(4), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

TDS was allowable to be deducted. Accordingly, the order of the ld. CIT 15 ITA No. 3068/Mum/2024 and others M/s. Patel Engineering Limited (A) is confirmed and the grounds raised by the Revenue in both the years are dismissed. ITA NOs.2801/Mum/2024 & 3063/Mum/2024 19. These are the cross appeals filed by the assessee as well as by the Revenue against order

ASST.COMMISSIONER OF INCOME TAX, TDS 2 1, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

TDS was allowable to be deducted. Accordingly, the order of the ld. CIT 15 ITA No. 3068/Mum/2024 and others M/s. Patel Engineering Limited (A) is confirmed and the grounds raised by the Revenue in both the years are dismissed. ITA NOs.2801/Mum/2024 & 3063/Mum/2024 19. These are the cross appeals filed by the assessee as well as by the Revenue against order

DCIT CC - 3(4), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

TDS was allowable to be deducted. Accordingly, the order of the ld. CIT 15 ITA No. 3068/Mum/2024 and others M/s. Patel Engineering Limited (A) is confirmed and the grounds raised by the Revenue in both the years are dismissed. ITA NOs.2801/Mum/2024 & 3063/Mum/2024 19. These are the cross appeals filed by the assessee as well as by the Revenue against order

PATEL ENGINEERING LIMITED ,MUMBAI vs. DCIT-CC-3(4), MUMBAI

TDS was allowable to be deducted. Accordingly, the order of the ld. CIT 15 ITA No. 3068/Mum/2024 and others M/s. Patel Engineering Limited (A) is confirmed and the grounds raised by the Revenue in both the years are dismissed. ITA NOs.2801/Mum/2024 & 3063/Mum/2024 19. These are the cross appeals filed by the assessee as well as by the Revenue against order

ASST.COMMISSIONER OF INCOME-TAX (TDS)2(1), MUMBAI, MUMBAI vs. PATEL ENGINEERING LIMITED, MUMBAI

TDS was allowable to be deducted. Accordingly, the order of the ld. CIT 15 ITA No. 3068/Mum/2024 and others M/s. Patel Engineering Limited (A) is confirmed and the grounds raised by the Revenue in both the years are dismissed. ITA NOs.2801/Mum/2024 & 3063/Mum/2024 19. These are the cross appeals filed by the assessee as well as by the Revenue against order

ACIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, cross objection filed by the assessee is partly allowed

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

801A, which states that nothing contained in this section shall apply to a person who executes a work contract entered into with the undertaking or enterprises ". 2. "On the facts and in the circumstances of the case and in law, the CIT(A) erred in allowing that the credit of TDS

ACIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, cross objection filed by the assessee is partly allowed

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

801A, which states that nothing contained in this section shall apply to a person who executes a work contract entered into with the undertaking or enterprises ". 2. "On the facts and in the circumstances of the case and in law, the CIT(A) erred in allowing that the credit of TDS

PATEL ENGINEERING LIMITED ,MUMBAI vs. DCIT CC-3(4), MUMBAI

In the result, appeals of the Revenue are dismissed, except for one ground no

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

TDS was allowable to be deducted. Accordingly, the order of the ld. CIT M/s. Patel Engineering Limited (A) is confirmed and the grounds raised by the Revenue in both the years are dismissed. ITA NOs.2801/Mum/2024 & 3063/Mum/2024 19. These are the cross appeals filed by the assessee as well as by the Revenue against order dated 22/03/2024 passed

DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), MUMBAI, MUMBAI vs. ULTRATECH CEMENT LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Section 801A(12A) of\nthe Income Tax Act, 1961 and that the revenue has preferred an appeal\nbefore the Hon'ble Bombay High Court on the same issue for 2010-11, 2012-\n13, 2013-14 & 2014-15?\"\n5. “Whether on the facts and in the circumstances of the case and in law, the Ld.\nCIT(A) is right

ASST CIT CEN CIR 25, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal of revenue is dismissed, whereas cross objection of the assessee is allowed in part, in terms indicated hereinabove

TDS Credit on advances received; vii) Computation of income u/s.115JB; viii) Interest u/s.234B; ix) Interest u/s.234D; and x) Initiation of Penalty proceedings u/s.271(1)(c) 3. The A.O has analyzed the various Agreements entered into and arrived at a finding that the assessee is merely a contractor as is referred to in all its Agreements with the various authorities

ADDL CIT LTU, MUMBAI vs. BAJAJ HOLDING & INVESTMENT LTD ( FOREMERLY KNOWN AS BAJAJ AUTO LTD), MUMBAI

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee stands partly allowed as indicated hereinabove

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

TDS on premium paid on the lease hold land is required to be deducted by payer. He submitted that the tax of the present assessee is similar to the facts of these cases only to the extent in which the lease transaction is entered into by the assessee. The Ld. Sr. Counsel further submitted that in none of the above

SAROVAR HOTELS P.LTD,MUMBAI vs. DCIT CIR 3(3), MUMBAI

Accordingly, the grounds raised by the assessee are partly allowed

Bench: Shri S. Rifaur Rahman, Am & Shri Ramlal Negi, Jm आयकरअपीलसं./ I.T.A. No. 7348/Mum/2016 (निर्धारणवर्ा / Assessment Year: 2011-12) M/S. Sarovar Hotels Dcit Circle 3(3), Aayakar Bhavan, 6Th P.Ltd 42 Mittal बिधम/ Fl., R. No. 609, M. K. Chambers, Nariman Vs. Road, Point, Mumbai- 400 Mumbai-400 020 021. स्थायीलेखासं./जीआइआरसं./Pan No.Aaacs8083L (अपीलाथी/Appellant) (प्रत्यथी / Respondent) :

TDS assuming that it is not for business purpose without considering the facts and circumstances of the case. The same be deleted. 3) The assessee craves leave to add, alter, amend or delete the grounds of appeal at the time of or before the hearing. 8.Before us, the ld. AR brought to our notice facts of the case and brought

VODAFONE DIGILINK LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee Ground Nos 9 & 10 is allowed

Bench: Shri Anikesh Banerjeeand\Nshri Prabhash Shankar\Nita No.1169/Mum/2014\N(Assessment Year: 2009-10)\Nm/S Vodafone Digilink Vs Deputy Commissioner Of Income\Nlimited,\Ntax, Cir.17(1), New Delhi\Nc-48, Okhla Industrial Area,\Nphase-Ii, New Delhi-110 020\Npan: Aaaca3202D\Nappellant\Nrespondent\Nassessee By\N:\Nshri Percy J. Pardiwalla/Wshri\Nketan Ved\Nrespondent By\N:\Nms. Vatsala Jha (Pcit)\Ndate Of Hearing\N:\N23/12/2024\Ndate Of Pronouncement\N:\N12/02/2025\Norder\Nper Anikesh Banerjee:\Ninstant Appeal Of The Assessee Was Filed Against The Order Of The Learned\Ndispute Resolution Panel-Ii, New Delhi-02 [For Brevity, ‘Ld.Drp') Passed Under\Nsection 144C(5) Of The Income-Tax Act, 1961 (For Brevity, ‘The Act'),\Ndated21/11/2013 For A.Y. 2009-10. The Impugned Order Was Emanated From The\Ndraft Assessment Order U/S 144C(1) R.W.S.143(3) Of The Actdated 28/03/2013 Of\Nthe Ld.Dcit, Circle-17(1), New Delhi (For Brevity The Ld. Ao).\N2\Nita No.1169/Mum/2014\Nvodafone Digilink Limited\N2. The Assessee Has Raised The Following Grounds Of Appeal: -\N“The Appellant Respectfully Submits That:\Non The Facts & Circumstances Of The Case & In Law, The Learned Dispute\Nresolution Panel -11. New Delhi (Drp\") Has Erred In Passing The Order Under\Nsection 144C(5) Of The Income Tax Act, 1961 (Act\"), Partly Confirming The\Nadjustments Proposed By The Deputy Commissioner Of Income Tax, Circle 17(1)\Nnew Delhi ("Ao') In The Draft Assessment Order & The Learned Ao Has\Naccordingly Erred In Passing The Assessment Order Under Section 143(3) Read With\Nsection 144C Of The Act.\Neach Of The Ground Is Referred To Separately, Which May Kindly Be Considered\Nindependent Of Each Other.\N1. On Amortization Of Revenue Based License Fee U/S 35Abb Of The Act\N1.

801A of the Act.\n8. Disallowance of unsecured loans/security deposits\n8. 1. On the facts and in the circumstances of the case and in law, the learned\nAO/DRP has erred in disallowing unsecured loans/security deposit amounting to\nRs 2,00,75,850 obtained by Appellant during the subject year under Section 68 of\nthe Act.\n9. Transfer Pricing adjustment - Disallowance

ULTRA TECH CEMENT LTD.,MUMBAI vs. ASSTT. CIT CC-1(4), MUMBAI

In the result, appeal of the assessee is allowed for statistical purposes

section 801A(12A) of the IT Act. 5. On the facts and in the circumstances of the case and in law, the learned Commissioner of Income-tax (Appeals) [CIT(A)] has erred in not directing the learned JCIT to allow claim of TDS

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

section 199(2) of the IT Act, 1961, since the advances pertaining thereto are not credited in the P & L A/C of the assessee in the FY under consideration". 4. "On the facts and in the circumstances of the case and in law, the CIT(A) was justified in holding that the assessee is eligible for enhanced claim of deduction

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

section 199(2) of the IT Act, 1961, since the advances pertaining thereto are not credited in the P & L A/C of the assessee in the FY under consideration". 4. "On the facts and in the circumstances of the case and in law, the CIT(A) was justified in holding that the assessee is eligible for enhanced claim of deduction